"Information technology is an integral and critical ingredient for the successful functioning of major U.S. companies."
-- Deloitte & Touche LLP Survey of American Business Leaders, November 1996
The organizations we studied recognized that information and information systems were critical assets essential to supporting their operations that must be protected. As a result, they viewed information protection as an integral part of their business operations and of their strategic planning.
Senior Executive Support Is Crucial
In particular, senior executive recognition of information security risks and interest in taking steps to understand and manage these risks were the most important factors in prompting development of more formal information security programs. Such high-level interest helped ensure that information security was taken seriously at lower organizational levels and that security specialists had the resources needed to implement an effective program.
This contrasts with the view expressed to us by numerous federal managers and security experts that many top federal officials have not recognized the indispensable nature of electronic data and automated systems to their program operations. As a result, security-related activities intended to protect these resources do not receive the resources and attention that they merit.
In some cases, senior management's interest had been generated by an incident that starkly illustrated the organization's information security vulnerabilities, even though no damage may have actually occurred. In other cases, incidents at other organizations had served as a "wake-up call." Two organizations noted that significant interest on the part of the board of directors was an important factor in their organizations' attention to information security. However, security managers at many of the organizations told us that their chief executive officers or other very senior executives had an ongoing interest in information technology and security, which translated into an organizationwide emphasis on these areas.
Although the emphasis on security generally emanated from top officials, security specialists at lower levels nurtured this emphasis by keeping them abreast of emerging security issues, educating managers at all levels, and by emphasizing the related business risks to their own organizations.
Security Seen As An Enabler
In addition, most of the organizations were aggressively exploring ways to improve operational efficiency and service to customers through new or expanded applications of information technology, which usually prompted new security considerations. Officials at one organization viewed their ability to exploit information technology as giving them a significant competitive advantage. In this regard, several organizations told us that security was increasingly being viewed as an enabler--a necessary step in mitigating the risks associated with new applications involving Internet use and broadened access to the organization's computerized data. As a result, security was seen as an important component in improving business operations by creating opportunities to use information technology in ways that would not otherwise be feasible.
Practice 2: Develop Practical Risk Assessment Procedures That Link
Security to Business Needs
The organizations we studied had tried or were exploring various risk assessment methodologies, ranging from very informal discussions of risk to fairly complex methods involving the use of specialized software tools. However, the organizations that were the most satisfied with their risk assessment procedures were those that had defined a relatively simple process that could be adapted to various organizational units and involved a mix of individuals with knowledge of business operations and technical aspects of the organization's systems and security controls.
The manufacturing company had developed an automated checklist that asked business managers and relevant staff in individual units a series of questions that prompted them to consider the impact of security controls, or a lack thereof, on their unit's operations. The results of the analysis were reported in a letter to senior management that stated the business unit's compliance with the security policy, planned actions to become compliant, or willingness to accept the risk. The results were also reported to the internal auditors, who used them as a basis for reviewing the business unit's success in implementing the controls that the unit's managers had determined were needed. Through the reporting procedure, the business managers took responsibility for either tolerating or mitigating security risks associated with their operations.
Such procedures provided a relatively quick and consistent means of exploring risk with business managers, selecting cost-effective controls, and documenting conclusions and business managers' acceptance of final determinations regarding what controls were needed and what risks could be tolerated. With similar objectives in mind, the utility company had developed a streamlined risk assessment process that brought together business managers and technical experts to discuss risk factors and mitigating controls. (This process is described in detail as a case example on page 27.)
Other organizations had developed less formal and comprehensive techniques for ensuring that risks were considered prior to changes in operations.
n The retailer had established standard procedures for requesting and granting new network connections. Under these procedures, documentation about the business need for the proposed connection and the risks associated with the proposed connection had to be submitted in writing prior to consideration by the central security group. Then, a meeting between the technical group, which implemented new connections, the requester, and the central security group was held to further explore the issue. The documentation and meeting helped ensure that the requester's business needs were clearly understood and the best solution was adopted without compromising the network's security.
n The financial services corporation had implemented procedures for documenting business managers' decisions to deviate from organizationwide policies and standards. In order to deviate from a "mandatory policy," the business unit prepared a letter explaining the reason for the deviation and recognizing the related risk. Both the business unit executive and the central security group manager signed the letter to acknowledge their agreement to the necessity of the policy deviation. Deviations from less rigid "standards" were handled similarly, although the letter could be signed by the business unit executive, alone, and did not require the central security group's approval, though it was generally received. In all cases, the central security group discussed the information security implications of the deviation with the appropriate executive and signed-off only when it was satisfied that the executives fully understood the risk associated with the deviation. However, the ultimate decision on whether a deviation from policies or standards was appropriate was usually left to the business unit.
Organizations Saw Benefits Despite Lack of Precision
"Actual losses are not necessarily good indications of risk."
-- Security manager at a prominent financial institution
Although all of the organizations placed emphasis on understanding risks, none attempted to precisely quantify them, noting that few quantified data are available on the likelihood of an incident occurring or on the amount of damage that is likely to result from a particular type of incident. Such data are not available because many losses are never discovered and others are never reported, even within the organizations where they occurred. In addition, there are limited data on the full costs of damage caused by security weaknesses and on the operational costs of specific control techniques. Further, due to fast-paced changes in technology and factors such as the tools available to would-be intruders, the value of applying data collected in past years to the current environment is questionable. As a result, it is difficult, if not impossible, to precisely compare the cost of controls with the risk of loss in order to determine which controls are the most cost-effective. Ultimately, business managers and security specialists must rely on the best information available and their best judgment in determining what controls are needed.
Despite their inability to precisely compare the costs of controls with reductions in risk, the organizations said that risk assessments still served their primary purpose of ensuring that the risk implications of new and existing applications were explored. In particular, the security managers believed that adequate information was available to identify the most significant risks. For example, in addition to their own organization's experience, they noted that information on threats, specific software vulnerabilities, and potential damage was widely available in technical literature, security bulletins from organizations such as the Carnegie-Mellon Computer Emergency Response Team (CERT), surveys done by professional associations and audit firms, and discussion groups. Although much of this information was anecdotal, the security managers thought that it was sufficient to give them a good understanding of the threats of concern to their organizations and of the potential for damage.
In addition, the lack of quantified results did not diminish the value of risk assessments as a tool for educating business managers. By increasing the understanding of risks, risk assessments (1) improved business managers' ability to make decisions on controls needed, in the absence of quantified risk assessment results, and (2) engendered support for policies and controls adopted, thus helping to ensure that policies and controls would operate as intended.
Practice 3: Hold Program and Business Managers Accountable
"Holding business managers accountable and changing the security staff's role from enforcement to service has been a major paradigm shift for the entire company."
-- Security manager at a major equipment manufacturer
The organizations we studied were unanimous in their conviction that business managers must bear the primary responsibility for determining the level of protection needed for information resources that support business operations. In this regard, most held the view that business managers should be held accountable for managing the information security risks associated with their operations, much as they would for any other type of business risk. However, security specialists played a strong educational and advisory role and had the ability to elevate discussions to higher management levels when they believed that risks were not being adequately addressed.
Business managers, usually referred to as program managers in federal agencies, are generally in the best position to determine which of their information resources are the most sensitive and what the business impact of a loss of integrity, confidentiality, or availability would be. Business or program managers are also in the best position to determine how security controls may impair their operations. For this reason, involving them in selecting controls can help ensure that controls are practical and will be implemented.
Accordingly, security specialists had assumed the role of educators, advisors, and facilitators who helped ensure that business managers were aware of risks and of control techniques that had been or could be implemented to mitigate the risks. For several of the organizations, these roles represented a dramatic reversal from past years, when security personnel were viewed as rigid, sometimes overly protective enforcers who often did not adequately consider the effect of security controls on business operations.
Some of the organizations had instituted mechanisms for documenting and reporting business managers' risk determinations. These generally required some type of sign-off on memoranda that either (1) reported deviations from predetermined control requirements, as was the case at the financial services corporation and the manufacturing company discussed previously or (2) provided the results of risk assessments, as was the case of the utility company described in the following case example. According to the security managers, such sign-off requirements helped ensure that business managers carefully considered their decisions before finalizing them.
Each risk analysis session takes approximately 4 hours and includes 7 to 15 people, though sessions with as many as 50 and as few as 4 people have occurred. Additional time is usually needed to develop the action plan. The information security group conducts between 8 and 12 sessions a month. According to the utility's central information security group, this process increases security awareness among business managers, develops support for needed controls, and helps integrate information security considerations into the organization's business operations.
Practice 4: Manage Risk on a Continuing Basis
"Information security is definitely a journey, not a destination--there are always new challenges to meet."
-- Chief information security officer at a major financial services corporation
The organizations emphasized the importance of continuous attention to security to ensure that controls were appropriate and effective. They stressed that constant vigilance was needed to ensure that controls remained appropriate--addressing current risks and not unnecessarily hindering operations--and that individuals who used and maintained information systems complied with organizational policies.
Such attention is important for all types of internal controls, but it is especially important for security over computerized information, because, as mentioned previously, the factors that affect computer security are constantly changing in today's dynamic environment. Such changing factors include threats, systems technologies and configurations, known vulnerabilities in existing software, the level of reliance on automated systems and electronic data, and the sensitivity of such operations and data.
Existing Federal Guidance Provides a Framework for Implementing Risk Management Practices
OMB's 1996 revision of Circular A-130, Appendix III, recognizes that federal agencies have had difficulty in performing effective risk assessments--expending resources on complex assessments of specific risks with limited tangible benefits in terms of improved security. For this reason, the revised circular eliminates a long-standing federal requirement for formal risk assessments. Instead, it promotes a risk-based approach and suggests that, rather than trying to precisely measure risk, agencies focus on generally assessing and managing risks. This approach is similar to that used by the organizations we studied.
Similarly, the concept of holding program managers accountable underlies the existing federal process for accrediting systems for use. Accreditation is detailed in NIST's Federal Information Processing Standards Publication 102, Guideline for Computer Security Certification and Accreditation, which was published in 1983. According to NIST, accreditation is "the formal authorization by the management official for system operation and an explicit acceptance of risk." OMB's 1996 update to Circular A-130, Appendix III, provides similar guidance, specifying that a management official should authorize in writing the use of each system before beginning or significantly changing use of the system. "By authorizing processing in a system, a manager accepts the risks associated with it."
| Getting Started--Assessing Risk and Determining Needs | |
Senior Program Officials |
Gain an understanding of
the criticality and sensitivity of the information and systems that support key agency
programs. Recognize that information security risks to program operations are potentially significant and support efforts to further explore and understand these risks as they relate to your agency's operations. Review discussions made by subordinate managers regarding the levels of information protection needed and take responsibility for making final determinations. Monitor implementation of the risk assessment process to ensure that it is providing benefits and does not evolve into a "paperwork exercise." |
CIOs |
Define risk assessment
processes that involve senior program officials and require them to make final
determinations regarding the level of information protection needed. Ensure that security specialists and other technical experts are available to educate and advise program officials regarding potential vulnerabilities and related controls. |
Senior Security Officers |
Promote and facilitate
the risk assessment process by (1) developing practical risk assessment procedures and
tools, (2) arranging for risk assessment sessions, (3) ensuring the involvement of key
program and technical personnel, and (4) providing mechanisms for documenting final
decisions. In promoting the adoption of policies and other controls, focus on the specific business reasons for the controls rather than on generic requirements. |
"A central focal point is essential to spotting trends, identifying problem areas, and seeing that policies and administrative actions are handled in a consistent manner."
-- Senior information security officer for a major university
"Information security has become too important to handle on an ad hoc basis."
-- Security specialist at a major retailing company
Managing the increased risks associated with a highly interconnected computing environment demands increased central coordination to ensure that weaknesses in one organizational unit's systems do not place the entire organization's information assets at undue risk. Each of the organizations we studied had adopted this view and, within the last few years, primarily since 1993, had established a central security management group or reoriented an existing central security group to facilitate and oversee the organization's information security activities. As such, the central group served as the focal point for coordinating activities associated with the four segments of the risk management cycle.
As discussed in the previous section on risk analysis, the central security groups served primarily as advisers or consultants to the business units, and, thus, they generally did not have the ability to independently dictate information security practices. However, most possessed considerable "clout" across their organizations due largely to the support they received from their organization's senior management. In this regard, their views were sought and respected by the organizations' business managers. The following case example describes how one organization strengthened its central security group and reoriented its focus.
| Case Example: Transforming an Organization's
Central Security Focal Point In 1995, realizing that security was an essential element of its efforts to innovatively use information technology, a major manufacturer significantly reorganized and strengthened its central information security function. Prior to the reorganization, a central security group of about four individuals concentrated on mainframe security administration and had little interaction with the rest of the company. Since then, the central group has grown to include 12 individuals who manage the security of the company's (1) main network, (2) decentralized computer operations, and (3) Internet use. In addition, the group participates in the company's strategic planning efforts and in the early stages of software development projects to ensure that security implications of these efforts are addressed. In this regard, it serves as a communications conduit between management and the information systems staff who design, build, and implement new applications. Members of the central group possess a variety of technical skills and have specific information security responsibilities, such as developing policy, maintaining the firewall that protects the organization's network from unauthorized intrusions, or supporting security staff assigned to individual business units. According to the group's manager, because of the shift in the central group's responsibilities, "the members of the group had to change their mind-set from a staff organization to a service organization. They had to be willing to work with business managers to enable rather than to control business operations." |
Practice 5: Designate a Central Group to Carry Out Key Activities
Overall, the central security groups served as (1) catalysts for ensuring that information security risks were considered in both planned and ongoing operations, (2) central resources for advice and expertise to units throughout their organizations, and (3) a conduit for keeping top management informed about security-related issues and activities affecting the organization. In addition, these central groups were able to achieve some efficiencies and increase consistency in the implementation of the organization's security program by performing tasks centrally that might otherwise be performed by multiple individual business units.
Specific activities performed by central groups differed somewhat, primarily because they relied to a varying extent on security managers and administrators in subordinate units and on other organizationally separate groups, such as disaster recovery or emergency response teams. Examples of the most common activities carried out by central groups are described below.
n Developing and adjusting organizationwide policies and guidance, thus reducing redundant policy-related activities across the organization's units. For example, the manufacturer's central security group recently revamped the company's entire information security manual and dedicated one staff member to maintaining it.
n Educating employees and other users about current information security risks and helping to ensure consistent understanding and administration of policies through help-line telephone numbers, presentations to business units, and written information communicated electronically or through paper memos.
n Initiating discussions on information security risks with business managers and conducting defined risk assessment procedures.
n Meeting periodically with senior managers to discuss the security implications of new information technology uses being considered.
n Researching potential threats, vulnerabilities, and control techniques and communicating this information to others in the organization. Many of the organizations supplemented knowledge gained from their own experiences by frequently perusing professional publications, alerts, and other information available in print and through the Internet. Several mentioned the importance of networking with outside organizations, such as the International Information Integrity Institute, the European Security Forum, and the Forum of Incident Response and Security Teams, to broaden their knowledge. One senior security officer noted, "Sharing information and solutions is important. Many organizations are becoming more willing to talk with outsiders about security because they realize that, despite differing missions and cultures, they all use similar technology and face many of the same threats."
n Monitoring various aspects of the organization's security-related activities by testing controls, accounting for the number and types of security incidents, and evaluating compliance with policies. The central groups often characterized these evaluative activities as services to the business units.
n Establishing a computer incident response capability, and, in some cases, serving as members of the emergency response team.
n Assessing risks and identifying needed policies and controls for general support systems, such as organizationwide networks or central data processing centers, that supported multiple business units. For example, some central groups controlled all new connections to the organization's main network, ensuring that the connecting network met minimum security requirements. Similarly, one organization's central group was instrumental in acquiring a strong user authentication system to help ensure that network use could be reliably traced to the individual users. Further, most central groups oversaw Internet use.
n Creating standard data classifications and related definitions to facilitate protection of data shared among two or more business units.
n Reviewing and testing the security features in both commercially developed software that was being considered for use and internally developed software prior to its being moved into production. For example, the manufacturing company's central group reviewed all new Internet related applications and had the authority to stop such applications from going into production if minimum security standards were not met. Similarly, the central information protection group at the utility was required to approve all new applications to indicate that risks had been adequately considered.
n Providing self-assessment tools to business units so that they could monitor their own security posture. For example, the financial services corporation provided business units with software tools and checklists so that they would assume responsibility for identifying and correcting weaknesses rather than depending on auditors to identify problems.
Practice 6: Provide the Central Group Ready and Independent Access to Senior Executives
Senior information security managers emphasized the importance of being able to discuss security issues with senior executives. Several noted that, to be effective, these senior executives had to be in a position to act and effect change across organizational divisions. The ability to independently voice security concerns to senior executives was viewed as important because such concerns could often be at odds with business managers' and system developers' desires to implement new computer applications quickly and avoid controls that would impede efficiency, user friendliness, and convenience. This ability to elevate significant security concerns to higher management levels helped ensure that risks were thoroughly understood and that decisions as to whether such risks should be tolerated were carefully considered before final decisions were made.
The organizational positions of the central groups varied. Most were located two levels below the Chief Information Officer (CIO). However, the groups reporting directly to the CIO or to an even more senior official viewed this as an advantage because it provided them greater independence. Several others said that, despite their lower organizational position, they felt free to contact their CIOs and other senior executives when important security issues arose, and they were relatively unrestrained by the need to "go through the chain of command." Some noted that senior managers frequently called them to discuss security issues. For example, at the nonbank financial institution, the senior security manager was organizationally placed two levels below the CIO, but she met independently with the CIO once every quarter. Also, during the first three months of 1997, she had met twice with the organization's chief executive officer, at his request, to discuss the security implications of new applications.
In contrast, several federal information security officials told us that they felt that their organizations were placed too low in the organizational structure to be effective and that they had little or no opportunity to discuss information security issues with their CIOs and other senior agency officials.
Rather than depend on the personal interest of individual senior managers, two of the organizations we studied had established senior-level committees to ensure that information technology issues, including information security, received appropriate attention. For example, the university's central group had created a committee of respected university technical and policy experts to discuss and build consensus about the importance of certain information security issues reported to senior management, thus lending weight and credibility to concerns raised by the central security office.
Practice 7: Designate Dedicated Funding and Staff
Unlike many federal agencies, the central groups we studied had defined budgets, which gave them the ability to plan and set goals for their organization's information security program. At a minimum, these budgets covered central staff salaries and training and security hardware and software. At one organization, business units could supplement the central group's resources in order to increase the central group's participation in high priority projects. While all of the central groups had staffs ranging from 3 to 17 people permanently assigned to the group, comparing the size of these groups is of limited value because of wide variations in the (1) sizes of the organizations we studied, (2) inherent riskiness of their operations, and (3) the additional support the groups received from other organizational components and from numerous subordinate security managers and administrators.
In particular, no two groups were alike regarding the extent of support they received from other organizational units. For example, the computer vendor relied on a security manager in each of the organization's four regional business units, while the utility's nine-member central group relied on 48 part-time information security coordinators at various levels within the company. Some central groups relied heavily on technical assistance located in another organizational unit, while others had significant technical expertise among their own staff, and, thus, were much more involved in directly implementing and testing controls.
Despite these differences, two key characteristics were common to each of the organizations: (1) information security responsibilities had been clearly defined for the groups involved and (2) dedicated staff resources had been provided to carry out these responsibilities. The following table summarizes the details on the size and structure of the organizations' information security staffs.
Placement and Staffing of Eight Central
Information Security Management Groups
| Organization | Approximate number of system users | Placement of central group | Number of dedicated central staff |
Other staff resources relied on (some numbers are approximate) |
| Financial services corporation | 70,000 |
Two levels below CEO | 17 |
n 35 security officers in business units |
| Electric utility | 5,000 |
One level below CIO | 9 |
n 48 security coordinators at three levels throughout the organization n Virus response team n Administrators |
| State university | 100,000 |
One level below CIO | 3 |
n 170 LAN administrators n Technical committee n Policy committee n Incident handling team |
| Retailer | 65,000 |
Two levels below CIO | 12 |
n 2,000 distributed security administrators n Internal audit staff n Technical services group n Loss prevention staff |
| State agency | 8,000 |
Two levels below CIO | 8 |
n 25 district managers n Security administrators in 31 units n Individuals with specialized expertise in the information systems group |
| Nonbank financial institution |
3,500 |
Two levels below CIO | 7 |
n Central security administration group |
| Computer vendor |
15,000 |
Three levels below CIO | 4 |
n 27 regional security specialists |
| Equipment manufacturer | 35,000 |
Several levels below CIO | 12 |
n 70 site security administrators |
Practice 8: Enhance Staff Professionalism and Technical Skills
The organizations had taken steps to ensure that personnel involved in various aspects of their information security programs had the skills and knowledge they needed. In addition, they recognized that staff expertise had to be frequently updated to keep abreast of ongoing changes in threats, vulnerabilities, software, security techniques, and security monitoring tools. Further, most of the organizations were striving to increase the professional stature of their staff in order to gain respect from others in their organizations and attract competent individuals to security-related positions.
Update Skills and Knowledge of Security Managers and Specialists
The training emphasis for staff in the central security management groups, many of whom came to their groups with significant technical expertise, was on keeping staff skills and knowledge current. This was accomplished primarily through attendance at technical conferences and specialized courses on topics such as the security features of new software, as well as networking with other security professionals and reviewing the latest technical literature and bulletins. To maximize the value of expenditures on external training and events, one central group required staff members who attended these events to brief others in the central group on what they had learned.
In an effort to significantly upgrade the expertise of information security officers in its various business units, the central group at the financial services corporation had recently arranged for an outside firm to provide 5 weeks of training for these individuals. The training, which is planned to take place in
1-week increments throughout the year, is expected to entail a broad range of security-related topics, including general information security, encryption, access control, and how to build a better working relationship with the corporation's technical information systems group.
Citing an emerging trend, the senior information security managers had also started to create information security career paths and stress professional certification for security specialists. In particular, many organizations were encouraging their staff to become Certified Information Systems Security Professionals (CISSP). One security manager noted that security specialists also needed excellent communication skills if they were to effectively fulfill their roles as consultants and facilitators for business managers who were less technically expert regarding computers and telecommunications.
Educate System Administrators
Increasing the expertise of system administrators presented different challenges. System administrators are important because they generally perform day-to-day security functions, such as creating new system user accounts, issuing new passwords, and implementing new software. These tasks must be completed properly and promptly or controls, such as passwords and related access restrictions, will not provide the level of protection intended. In addition, system administrators are the first line of defense against security intrusions and are generally in the best position to notice unusual activity that may indicate an intrusion or other security incident. However, at the organizations we studied, as at federal agencies, security is often a collateral duty, rather than a full-time job, and the individuals assigned frequently have limited technical expertise. As a result, the effectiveness of individual system administrators in maintaining security controls and spotting incidents is likely to vary.
To enhance the technical skills of their security administrators and help ensure that all of them had the minimal skills needed, most of the groups had established special training sessions for them. For example,
n the manufacturer required new security administrators to spend 2 to 5 days in training with the central security group, depending on their technical skills, before they were granted authority to perform specific functions on the network, such as controlling the users' access rights;
n the central security group at the university held annual technical conferences for the university's systems administrators and engaged professional training organizations to offer on-campus training at very reduced rates; and
n the state agency held a biannual conference for systems administrators that included sessions related to their information security responsibilities.
Attract and Keep Individuals with Technical Skills
Most of the groups cited maintaining or increasing the technical expertise among their security staff as a major challenge, largely due to the high demand for information technology experts in the job market. In response, several said they offered higher salaries and special benefits to attract and keep expert staff. For example, the financial services corporation provided competitive pay based on surveys of industry pay levels, attempted to maintain a challenging work environment, and provided flexible work schedules and telecommuting opportunities that allowed most of the staff to work at home 1 day a week. In addition, provisions were made for staff to do the type of work they preferred, such as software testing versus giving presentations.
Organizations relied on both internally and externally developed and presented training courses, sometimes engaging contractors or others to assist. For example, the state information security office above the state agency worked with an information security professional organization to provide a relatively low-cost statewide training conference. The state organization provided meeting rooms and administrative support while the professional organization used its professional contacts to obtain knowledgeable speakers.
| Getting Started--Establishing a Central Focal Point | |
Senior Program Officials |
Involve agency security
specialists in the early planning stages of projects involving computer and/or network
support. Be accessible to agency security experts and open to considering the information security implications of any operations. |
CIOs |
Establish a central
group to serve as a center of knowledge and expertise on information security and to
coordinate agencywide security-related activities. Provide the central group adequate funding for staff resources, training, and security software tools. Be accessible to agency security specialists. Involve agency security experts in the early planning stages of system development or enhancement projects. Support efforts to attract and retain individuals with needed technical skills. |
Senior Security Officers |
Develop training plans
for increasing the expertise of security specialists and security administrators. Explore mechanisms for leveraging resources by drawing on the expertise of others within or outside of the agency. Develop methods for attracting and retaining individuals with needed technical skills. |
The organizations viewed information security policies as the foundation of their information security programs and the basis for adopting specific procedures and technical controls. As with any area of operations, written policies are the primary mechanism by which management communicates its views and requirements to its employees, clients, and business partners. For information security, as with other types of internal controls, these views and requirements generally flow directly from risk considerations, as illustrated in the management cycle depicted above.
As discussed earlier, our discussions with the eight organizations focused on their methods for developing and supporting policies and guidelines. We did not discuss the specific controls they had implemented due to the proprietary and often highly technical nature of this information.
Practice 9: Link Policies to Business Risks
The organizations stressed the importance of up-to-date policies that made sense to users and others who were expected to understand them. Many senior security managers told us that prior to the recent strengthening of their security programs, their organization's information security policies had been neglected and out-of-date, thus failing to address significant risks associated with their current interconnected computing environment. As a result, developing a comprehensive set of policies was one of their first steps in establishing an effective corporatewide security program. In addition, they emphasized the importance of adjusting policies continually to respond to newly identified risks or areas of misunderstanding. For example,
n At the financial services corporation, the central security group routinely analyzed the causes of security weaknesses identified by management and by auditors in order to identify policy and related control deficiencies.
n The university had recently developed more explicit policies on system administrator responsibilities in recognition of the critical role of system administration in a distributed environment.
n The manufacturing company had recently drafted policies on security incident response after an incident had exposed shortfalls in the company's guidance in this area.
A relatively new risk area receiving particular attention in organizational policies was user behavior. Many policies are implemented and, to some extent, enforced by technical controls, such as logical access controls that prevent individuals from reading or altering data in an unauthorized manner. However, many information security risks cannot be adequately mitigated with technical controls because they are a function of user behavior. In a networked environment, these risks are magnified because a problem on one computer can affect an entire network of computers within minutes and because users are likely to have easier access to larger amounts of data and the ability to communicate quickly with thousands of others. For example, users may accidentally disclose sensitive information to a large audience through electronic mail or introduce damaging viruses that are subsequently transmitted to the organizations entire network of computers. In addition, some users may feel no compunction against browsing sensitive organizational computer files or inappropriate Internet sites if there is no clear guidance on what types of user behavior are acceptable.
To address these risks, many of which did not exist prior to extensive use of networks, electronic mail, and the Internet, the organizations had begun placing more emphasis on user behavior in their policies and guidelines. For example, the university's policies went beyond the traditional warnings against password disclosure by including prohibitions against a variety of possible user actions. These included misrepresenting their identity in electronic communications and conducting and promoting personal commercial enterprises on the network. The senior security officer at this organization noted that, when rules such as this are aimed at users, it is especially important that they be stated in clearly understandable, relatively nontechnical language. The security officers at the computer vendor said that because the company's information security policies emphasized user behavior, they were included in the organization's employee code of conduct.
Practice 10: Distinguish Between Policies and Guidelines
"Detailed guidelines are an important supplement to the official policies because they educate users and serve as an awareness tool."
-- Security manager at a prominent financial institution
A common technique for making organizational information security policies more useful was to divide them into two broad segments: concise high-level policies and more detailed information referred to as guidelines or standards. Policies generally outlined fundamental requirements that top management considered to be imperative, while guidelines provided more detailed rules for implementing the broader policies. Guidelines, while encouraged, were not considered to be mandatory for all business units.
Distinguishing between organizational policies and guidelines provided several benefits. It allowed senior management to emphasize the most important elements of information security policy, provided some flexibility to unit managers, made policies easier for employees to understand, and, in some cases, reduced the amount of formal review needed to finalize updated policies.
Guidelines Can Serve As An Educational Tool
Several security managers said that short policies that emphasized the most important aspects of the organizations security concerns were more likely to be read and understood than voluminous and detailed policies. However, they noted that more detailed guidelines often provided answers to employees' questions and served as a tool for educating subordinate security managers and others who wanted a more thorough understanding of good security practices.
For example, the utility company had distilled the fundamental components of its information protection policies into less than one page of text. This narrative (1) stated that "Information is a corporate asset . . . . Information must be protected according to its sensitivity, criticality and value, regardless of the media on which it is stored, the manual or automated systems that process it, or the methods by which it is distributed," (2) outlined the responsibilities of information owners, custodians, and users, (3) defined the organization's three data classification categories, and (4) stated that each business unit should develop an information protection program to implement these policies. The policy statement then referred the reader to a 73-page reference guide that provided definitions, recommended guidelines and procedures, explanatory discussions, and self-assessment questionnaires designed to assist business units in understanding the need for the policies and how they could be implemented.
Guidelines Provide for Flexibility
Although the latitude granted to business units varied, providing both policies and guidelines allowed business units to tailor the guidelines to their own individual unit's information protection needs. It also reinforced the business managers' sense of ownership of their information assets.
For example, the large financial services corporation had divided its information security rules into "policies" and "standards." Policies were mandatory, high-level requirements that, with rare exception, had to be followed. An example of a policy was that units were required to use commercially developed software rather than developing unique software in-house. An example of a standard at the same institution was a prescribed minimum password length. At this organization, deviations from policies had to be documented in a letter signed by both the executive of the business group requesting the deviation and the central information security group's manager. However, deviations from standards required only approval from the group's executive. Such deviations were required to be documented in a letter and, though not required, were usually approved by the central security group. All deviations had to be renewed annually.
Practice 11: Support Policies Through the Central Security Group
Generally, the central security management groups were responsible for developing written corporatewide policies in partnership with business managers, internal auditors, and attorneys. In addition, the central groups provided related explanations, guidance, and support to business units. Several security managers noted that business managers are much more likely to support centrally developed policies if they clearly address organizational needs and are practical to implement. For this reason, these organizations had developed mechanisms for involving other organizational components in policy documentation.
Most often this involvement was in the form of reviews of policy drafts. However, the university had established an information security policy committee that included top university officials, legal counsel, and representatives from student affairs, faculty affairs, and internal audit to assist in the development and review of policies.
The central security management groups played an important role in ensuring that policies were consistently implemented by serving as focal points for user questions. By serving as a readily available resource for organization employees, they helped clear up misunderstandings and provided guidance on topics that were not specifically addressed in written guidance.
Most organizations had also made their policies available through their computer networks so that users could readily access the most up-to-date version whenever they needed to refer to them. In addition, many organizations required users to sign a statement that they had read and understood the organization's information security policies. Generally, such statements were required from new users at the time access to information resources was first provided and from all users periodically, usually once a year. One security manager thought that requiring such signed statements served as a useful technique for impressing on the users the importance of understanding organizational policies. In addition, if the user was later involved in a security violation, the statement served as evidence that he or she had been informed of organizational policies. Additional techniques for communicating information security policies are discussed in the next section on promoting awareness.
| Getting Started--Implementing Appropriate Policies and Related Controls | |
Senior Program Officials |
Review existing policies and assist in developing new policies to ensure that they address current business risks and related information protection needs. |
CIOs |
Assign responsibility to
the central security group for coordinating the development of written policies that
address current risks. Institute procedures for periodically updating policies. |
Senior Security Officers |
Document policies
clearly so that they can be readily understood by managers and users. Review existing policies to identify the need to distinguish between official policies and guidelines. |
"Users are much more likely to support and comply with policies if they clearly understand the purpose for the policies and their responsibilities in regard to the policies.
"-- Information security manager for a state agency
User awareness is essential to successfully implementing information security policies and ensuring that related controls are working properly. Computer users, and others with access to information resources, cannot be expected to comply with policies that they are not aware of or do not understand. Similarly, if they are not aware of the risks associated with their organization's information resources, they may not understand the need for and support compliance with policies designed to reduce risk. For this reason, the organizations considered promoting awareness as an essential element of the risk management cycle.
Practice 12: Continually Educate Users and Others on Risks and Related Policies
The central groups had implemented ongoing awareness strategies to educate all individuals who might affect the organization's information security. These individuals were primarily computer users, who might be employees; contractors; clients; or commercial partners, such as suppliers. One organization took an even broader view, targeting awareness efforts also at custodians and security guards, after a night security guard accidentally destroyed some important data while playing games on a computer after hours.
The groups focused their efforts on increasing everyone's understanding of the risks associated with the organization's information and the related policies and controls in place to mitigate those risks. Although these efforts were generally aimed at encouraging policy compliance, the senior security official at the retailing company emphasized the importance of improving users' understanding of risks. She said that her central security group had recognized that policies, no matter how detailed, could never address every scenario that might lead to a security incident. As a result, her overarching philosophy regarding awareness efforts was that users who thoroughly understood the risks were better equipped to use good judgment when faced with a potential security breach. For example, such employees were less likely to be tricked into disclosing sensitive information or passwords.
This last point highlights one of the most important reasons for sensitizing computer users and other employees to the importance of information security. Users disclosing sensitive information or passwords in response to seemingly innocent requests from strangers either over the phone or in person can provide intruders easy access to an organization's information and systems. Such techniques, often referred to as "social engineering," exploit users' tendencies to be cooperative and helpful, instead of guarded, careful, and suspicious, when information is requested. Without adequate awareness about the risks involved in disclosing sensitive information, users may volunteer information which can allow an intruder to circumvent otherwise well-designed access controls.
Practice 13: Use Attention-Getting and User-Friendly Techniques
To get their message across, the central security groups used a variety of training and promotional techniques to make organizational policies readily accessible, educate users on these policies, and keep security concerns in the forefront of users' minds. Techniques used included
n intranet websites that communicated and explained information security- related policies, standards, procedures, alerts, and special notes;
n awareness videos with enthusiastic endorsements from top management for the security program to supplement basic guidance, such as the importance of backing up files and protecting passwords;
n interactive presentations by security staff to various user groups to market the services provided by the central information security group and answer user questions; and
n security awareness day and products with security-related slogans.
The organizations avoided having once-a-year, one-size-fits-all security briefings like those seen at many federal agencies. The security managers said that it was important to relate security concerns to the specific risks faced by users in individual business groups and ensure that security was an everyday consideration.
| Case Example - Coordinating Policy Development and
Awareness Activities After experiencing a significant virus infection in 1989, a retailing company assigned one of its managers to step up efforts to promote employee awareness of information security risks and related organizational policies. Since then, this individual's responsibilities for information security policy development and awareness, which had previously been handled on a part-time basis, have evolved into a full-time "awareness manager position" in the organization's central security group. The company's response to a minor incident involving the unintentional release of company financial data illustrates the compatibility of these roles. To reduce the chances of a similar incident, the awareness manager concurrently (1) coordinated the development of a policy describing organizational data classification standards and (2) developed a brochure and guidelines to publicize the new standards and educate employees on their implementation. By coordinating policy development and awareness activities in this manner, she helps ensure that new risks and policies are communicated promptly and that employees are periodically reminded of existing policies through means such as monthly bulletins, an intranet web site, and presentations to new employees. |
| Getting Started--Promoting Awareness | |
Senior Program Officials |
Demonstrate support by participating in efforts to promote information security awareness. |
CIOs |
Provide adequate funding and support to adequately promote awareness throughout the agency. |
Senior Security Officers |
Implement ongoing awareness strategies to educate all individuals who might affect the organization's information security. |
As with any type of business activity, information security should be monitored and periodically reassessed to ensure that policies continue to be appropriate and that controls are accomplishing their intended purpose. Over time, policies and procedures may become inadequate because of changes in threats, changes in operations, or deterioration in the degree of compliance. Periodic assessments or reports on activities can be a valuable means of identifying areas of noncompliance, reminding employees of their responsibilities, and demonstrating management's commitment to the security program.
The organizations we studied had recognized that monitoring control effectiveness and compliance with policies is a key step in the cycle of managing information security. Accordingly, they monitored numerous factors associated with their security programs, and they used the results to identify needed improvements. They used various techniques to do this, and several mentioned their efforts to identify, evaluate, and implement new, more effective tools as they become available. Such tools include software that can be used to automatically monitor control effectiveness and information systems activity. In addition, several of the security managers expressed interest in improving their ability to more precisely measure the costs and benefits of security-related activities so that their organizations could better determine which controls and activities were the most cost effective.
Practice 14: Monitor Factors that Affect Risk and Indicate Security Effectiveness
The organizations focused their monitoring efforts primarily on (1) determining if controls were in place and operating as intended to reduce risk and
(2) evaluating the effectiveness of the security program in communicating policies, raising awareness levels, and reducing incidents. As discussed below, these efforts included testing controls, monitoring compliance with policies, analyzing security incidents, and accounting for procedural accomplishments and other indicators that efforts to promote awareness were effective.
Testing the Effectiveness of Controls
Directly testing control effectiveness was cited most often as an effective way to determine if the risk reduction techniques that had been agreed to were, in fact, operating effectively. In keeping with their role as advisors and facilitators, most of the security managers said that they relied significantly on auditors to test controls. In these cases, the central security management groups kept track of audit findings related to information security and the organization's progress in implementing corrective actions.
However, several of the central security groups also performed their own tests. For example, the central security group at the university periodically ran a computer program designed to detect network vulnerabilities at various individual academic departments and reported weaknesses to department heads. A subsequent review was performed a few months later to determine if weaknesses had been reduced. The central security manager told us that she considered the tests, which could be performed inexpensively by her staff, a cost-effective way to evaluate this important aspect of security and provide a service to the academic departments, which were ultimately responsible for the security of their departments' information and operations.
Several organizations periodically tested system and network access controls by allowing designated individuals to try to "break into" their systems using the latest hacking techniques. This type of testing is often referred to as penetration testing. The individuals performing the tests, which at various organizations were internal auditors, contractors, student interns, or central security staff, were encouraged to research and use hacking instructions and tools available on the Internet or from other sources in order to simulate attacks from real hackers. By allowing such tests, the organizations could readily identify previously unknown vulnerabilities and either eliminate them or make adjustments in computer and network use to lessen the risks.
One organization had performed annual tests of its disaster recovery plan to identify and correct plan weaknesses. A recent test was particularly effective because it involved a comprehensive simulation of a real disaster. The test involved staging a surprise "bomb scare" to get employees, who were unaware that the threat was a pretense, to evacuate the building. After the employees had evacuated, they were told that they were participating in a test, that they were to assume that a bomb had actually destroyed their workplace, and to proceed with emergency recovery plans. The test, which was organized by the agency's contingency planning group, proved extremely successful in identifying plan weaknesses and in dramatically sensitizing employees to the value of anticipating and being prepared for such events.
Monitoring Compliance With Policies and Guidelines
All of the organizations monitored compliance with organizational policies to some extent. Much of this monitoring was achieved through informal feedback to the central security group from system administrators and others in other organizational units. However, a few organizations had developed more structured mechanisms for such monitoring. For example, the utility company developed quarterly reports on compliance with organizational policies, such as the number of organizational units that had tailored their own information protection policies as required by corporate-level policy. Also, several organizations said that they had employed self-assessment tools, such as the Computer Security Institute's "Computer Security Compliance Test," to compare their organization's programs to preestablished criteria.
Accounting For and Analyzing Security Incidents
Keeping summary records of actual security incidents is one way that an organization can measure the frequency of various types of violations as well as the damage suffered from these incidents. Such records can provide valuable input for risk assessments and budgetary decisions.
Although all of the organizations kept at least informal records on incidents, those that had formalized the process found such information to be a valuable resource. For example, at the nonbank financial institution, the central security manager kept records on viruses detected and eradicated, including estimates of the cost of potential damage to computer files that was averted by the use of virus detection software. This information was then used to justify annual budget requests when additional virus detection software was needed. However, as discussed in the following case example, the university had developed the most comprehensive procedures for accounting for and analyzing security incidents.
| Case Example: Developing an Incident Database A university's central security group had developed a database that served as a valuable management tool in monitoring problems, reassessing risks, and determining how to best use limited resources to address the most significant information security problems. The database accounted for the number of information security incidents that had been reported, the types of incidents, and actions taken to resolve each incident, including disciplinary actions. At the time of our visit, in February 1997, incidents were categorized into 13 types, which generally pertained to the negative effects of the violations. Examples included denial of service, unauthorized access, data compromise, system damage, copyright infringement, and unauthorized commercial activity. By keeping such records, the central group could develop monthly reports that showed increases and decreases in incident frequency, trends, and the status of resolution efforts. This, in turn, provided the central security group a means of (1) identifying emerging problems, (2) assessing the effectiveness of current policies and awareness efforts, (3) determining the need for stepped up education or new controls to address problem areas, and (4) monitoring the status of investigative and disciplinary actions to help ensure that no individual violation was inadvertently forgotten and that violations were handled consistently. The means of maintaining the database and the details that it contained had changed as the number of reported incidents at the university had grown--from 3 or 4 a month in 1993 to between 50 and 60 a month in early 1997--and as the database's value as a management tool became more apparent. Records originally maintained in a paper logbook had been transferred to a personal computer, and information on follow-up actions had recently been expanded. The university's senior security officer noted that the database could be augmented to provide an even broader range of security management information. For example, while the university did not develop data on the actual cost of incidents, such as the cost of recovering from virus infections, the database could be used to compile such information, which would be useful in measuring the cost of security lapses and in determining how much to spend on controls to reduce such lapses. |
Monitoring the Effectiveness of the Central Security Management Group
Several of the central security groups had developed measures of their own activities, outputs, and expertise as an indication of their effectiveness. Examples of these items included
n the number of calls from users, indicating knowledge of and respect for security specialists;
n the number of security-related briefings and training sessions presented;
n the number of risk assessments performed;
n the number of security managers and systems administrators who were Certified Information System Security Professionals; and
n the number of courses and conferences held or attended.
Emerging Interest in More Precisely Measuring Cost and Benefits
Several of the security managers expressed an interest in developing better measurement capabilities so that they could more precisely measure the ultimate benefits and drawbacks of security-related policies and controls--that is, the positive and negative affects of information security on business operations. However, they said that such measurements would be difficult because it is costly to do the research and recordkeeping necessary to develop information on (1) the full cost of controls--both the initial cost and operational inefficiencies associated with the controls--and (2) the full cost of incidents or problems resulting from inadequate controls. Further, as discussed previously regarding risk assessment, actual reductions in risk cannot be precisely quantified because sufficient data on risk factors are not available.
In an effort to more thoroughly explore this topic, we expanded our discussions beyond the eight organizations that were the primary subjects of our study by requesting the Computer Security Institute to informally poll its most active members on this subject. We also discussed assessment techniques with experts at NIST. Although we identified no organizations that had made significant progress in applying such measures, we found that more precisely measuring the positive and negative effects of security on business operations is an area of developing interest among many information security experts. For this reason, improved data and measurement techniques may be available in the future.
Practice 15: Use Results to Direct Future Efforts and Hold Managers Accountable
Although monitoring, in itself, may encourage compliance with information security policies, the full benefits of monitoring are not achieved unless results are used to improve the security program. Analyzing the results of monitoring efforts provides security specialists and business managers a means of
(1) reassessing previously identified risks, (2) identifying new problem areas, (3) reassessing the appropriateness of existing controls and security-related activities, (4) identifying the need for new controls, and (5) redirecting subsequent monitoring efforts. For example, the central security group at the utility redirected its training programs in response to information security weaknesses reported by its internal auditors. Similarly, security specialists at the manufacturing company recently visited one of the company's overseas units to assist in resolving security weaknesses identified by internal auditors. The previously cited example of using records on virus incidents to determine the need for virus-detection software also illustrates this point.
Results can also be used to hold managers accountable for their information security responsibilities. Several organizations had developed quarterly reporting mechanisms to summarize the status of security-related efforts. However, the financial services corporation provided the best example of how periodic reports of results can be used to hold managers accountable for understanding, as well as reducing, the information security risks to their business units. A description of this process is provided in the following case example.
| Case Example: Measuring Control Effectiveness
and Management Awareness At a major financial services corporation, managers are expected to know what their security problems are and to have plans in place to resolve them. To help ensure that managers fulfill this responsibility, they are provided self-assessment tools that they can use to evaluate the information security aspects of their operations. When weaknesses are discovered, the business managers are expected to either improve compliance with existing policies or consult with the corporation's security experts regarding the feasibility of implementing new policies or control techniques. Ratings based on audit findings serve as an independent measure of control effectiveness and management awareness. At the start of every audit, the auditors ask the pertinent business managers what weaknesses exist in their operations and what corrective actions they have deemed necessary and have planned. After audit work is complete, the auditors compare their findings with management's original assertions to see if management was generally aware of all of the weaknesses prior to the audit. The auditors then develop two ratings on a scale of 1 to 5: One rating to indicate the effectiveness of information security controls and a second rating to indicate the level of management awareness. If the auditors discover serious, but previously unrecognized weaknesses, the management awareness rating will be lowered. However, if the auditor finds no additional weaknesses, management will receive a good awareness rating, even if controls need to be strengthened. These ratings are forwarded to the CEO and to the board of directors, where they can be used as performance measures. According to the bank's central security manager, the bank chairman's goal is for all business units to have favorable ratings (4 or 5) in both categories. Such a rating system provides not only a measure of performance and awareness, but it also places primary responsibility for information security with the managers whose operations depend on it. Further, it recognizes the importance of identifying weaknesses and the risk they present, even when they cannot be completely eliminated. |
Practice 16: Be Alert to New Monitoring Tools and Techniques
The security specialists said that they were constantly looking for new tools to test the security of their computerized operations. Two security managers noted that their organizations had implemented new, more sophisticated, software tools for monitoring network vulnerabilities. However, several security managers said that the development of automated monitoring tools is lagging behind the introduction of new computer and network technologies and that this has impaired their efforts to detect incidents, especially unauthorized intrusions. Similarly, as discussed previously, managers are looking for practical techniques for more precisely measuring the value of security controls and obtaining better data on risk factors. In such an environment, it is essential that (1) security specialists keep abreast of developing techniques and tools and the latest information about system vulnerabilities and (2) senior executives ensure they have the resources to do this.
Several security managers told us that, in addition to reading current professional literature, their involvement with professional organizations was a valuable means of learning about the latest monitoring tools and research efforts. Examples of such organizations included the Computer Security Institute, Information Systems Security Association, the Forum of Incident Response and Security Teams, and less formal discussion groups of security professionals associated with individual industry segments. Several security managers said that by participating in our study, they hoped to gain insights on how to improve their information security programs.
| Getting Started--Monitoring and Evaluating Policy and Control Effectiveness | |
Senior Program Officials |
Determine what aspects of information security are important to mission-related operations and identify key indicators to monitor the effectiveness of related controls. |
CIOs |
Include security-related performance measures when developing information technology performance measures. |
Senior Security Officers |
Establish a reporting
system to account for the number and type of incidents and related costs. Establish a program for testing and evaluating key areas and indicators of security effectiveness. Develop a mechanism for reporting evaluation results to key business managers and others who can act to address problems. Become an active participant in professional associations and industry discussion groups in order to keep abreast of the latest monitoring tools and techniques. |
"We are on the verge of a revolution that is just as profound as the change in the economy that came with the industrial revolution. Soon electronic networks will allow people to transcend the barriers of time and distance and take advantage of global markets and business opportunities not even imaginable today, opening up a new world of economic possibility and progress."
Vice President Albert Gore, Jr., in the Administration's July 1997 report,
A Framework For Global Electronic Commerce
To achieve the benefits offered by the new era of computer interconnectivity, the federal government, like other organizational entities and individuals, must find ways to address the associated security implications. Individual security controls and monitoring tools will change as technology advances, and new risks are likely to emerge. For this reason, it is essential that organizations such as federal agencies establish management frameworks for dealing with these changes on an ongoing basis.
Developing an information security program that adheres to the basic principles outlined in this guide is the first and most basic step that an agency can take to build an effective security program. In this regard, agencies must continually (1) explore and assess information security risks to business operations, (2) determine what policies, standards, and controls are worth implementing to reduce these risks, (3) promote awareness and understanding among program managers, computer users, and systems development staff, and (4) assess compliance and control effectiveness. As with other types of internal controls, this is a cycle of activity, not an exercise with a defined beginning and end.
By instituting such a management framework, agencies can strengthen their current security posture, facilitate future system and process improvement efforts, and more confidently take advantage of technology advances.